Reforming the Community Reinvestment Act regulatory framework

National logos


November 19, 2018
Reforming the Community Reinvestment Act Regulatory Framework
Docket ID OCC-2018-0008


To Whom it May Concern:

The undersigned groups maintain that the Community Reinvestment Act (CRA) has been one of the most valuable laws for increasing access to capital and credit for low- and moderate-income (LMI) communities. Any CRA reform effort needs to tread carefully and build upon CRA’s success. When Senator Proxmire and other lawmakers were crafting CRA in 1977, their focus was on redlining in LMI communities and communities of color. As envisioned by the CRA statute, the antidote to redlining was CRA exams scrutinizing lending on a local level.

We agree that CRA needs an update. The agencies must expand assessment areas (geographical areas on CRA exams), require the inclusion of mortgage company affiliates on CRA exams, include communities of color on CRA exams, improve data, and increase opportunities for public input. In contrast, the OCC’s proposals would undermine CRA’s pillars of public input and local accountability and would thus result in significant declines in CRA-related loans, investments, and services. NCRC estimates that the OCC’s dilution of assessment areas and local accountability would result in a dramatic loss in home and small business lending over a five year time period that would range from $52 to $105 billion.[1]

Assessment Areas Must be Expanded

CRA exams currently reach conclusions about bank performance in assessment areas or geographical areas encompassing bank branches. For banks that make the great majority of their loans through branch networks, assessment areas are effective in rating them. However for other banks that use the internet or other non-branch means to make large numbers of loans, current assessment area definitions must change (ANPR Question 13). Assessment areas can include geographical areas such as states, metropolitan areas, or rural counties where banks do not have branches but have significant volumes of loans or other business activity. Some OCC exams including the Bank of the Internet designate assessment areas in this manner.[2] Inexplicitly, the ANPR does not build upon this precedent. Instead, it discusses how lending and other activities outside of areas with bank branches can be considered in “the aggregate.”[3] An “aggregate” consideration of activities outside of branch networks would not evaluate the activities in local areas and would fail to determine how responsive the activities were to local needs.

Estimates from studies conducted by Federal Reserve economists suggest that lending in LMI census tracts would be 10 to 20 percent lower when assessment areas are eliminated from exams or reduced in importance.[4] Any change in CRA must therefore retain assessment areas.

Automatic Inclusion of Affiliates on CRA Exams

CRA exams allow banks to either include or exclude their mortgage company affiliates on CRA exams. The natural tendency is for affiliates to be included on evaluations if they are lending to LMI borrowers and neighborhoods and to be excluded from exams if they are not. The optional inclusion of affiliates must be replaced with automatic inclusion.

People and Communities of Color Must be Considered on CRA Exams

In response to ANPR Questions 16 and 17, evaluations of lending to people and communities of color would further satisfy the original intent of the CRA legislation. During the 1977 hearings on CRA, Senator Proxmire stated, “banks will take their deposits from a community and instead of reinvesting them in that community, they will actually or figuratively draw a red line on a map around the areas of their city, sometimes in the inner city, sometimes in the older neighborhoods, sometimes ethnic and sometimes black, but often encompassing a great area of their neighborhood.”[5]

Before the last changes to the CRA regulation in 1995, CRA exams analyzed lending to minorities as part of the fair lending section, which could be readily revived.[6] In addition, the agencies could develop a list of underserved census tracts based on data analysis showing low levels of loans per capita. A substantial number of these tracts would likely be predominantly minority. Lending, investment, and services in these tracts then could be evaluated by CRA exams.

CRA Ratings Must be Made More Rigorous

During the past several years, more than 98 percent of banks have passed their CRA exams. If the pass rate was not this high, CRA would be even more effective in motivating increases in loans, investments, and services to LMI communities. One way to improve rigor is if the overall ratings were accompanied by a publicly released point score.[7] For example, an Outstanding rating could be achieved if a bank had a score of 90 to 100, while a Satisfactory rating could be achieved if a bank had a score of 70 to 90. This point scale would reveal more gradations in performance. For example, a Satisfactory rating accompanied by a score of 70 is just barely passing while a Satisfactory rating accompanied by a score of 89 is essentially a High Satisfactory rating.

Data Must be Improved on CRA Exams

The small business loan part of the lending test is not as rigorous as the home lending section because the small business data is not as detailed. Therefore, small business data must be improved to include more categories rather than only lending to businesses above and below $1 million in revenue. Likewise, the community development (CD) parts of the exam must be improved with annual CD data for census tracts and counties. In addition, banks must be penalized via lower ratings if their CD activity finances displacement of LMI people such as low-income tenants from multifamily housing.

Community Benefits Agreements and Conditional Approvals Considered on CRA Exams

We appreciate that the OCC’s June 2018 memo instructs CRA examiners to determine whether banks are meeting the goals in CRA plans required in conditional merger approvals.[8] Any conditional merger approval, however, must include a bona fide plan that focuses lending, investment, and service on LMI borrowers and communities. CRA examiners must also assess bank compliance with community benefit agreements (CBAs) that are negotiated with community groups and include clear goals. In addition, a passing CRA rating must not become a safe harbor providing expedited merger approvals. Bank performance may have changed since the last CRA exam, necessitating analysis of whether the merger will confer public benefits.

The OCC’s One Ratio Concept would Diminish Assessment Areas and Public Input

The one ratio would consist of the dollar amount of a bank’s CRA activities (loans, investments, and services to LMI borrowers and communities) divided by the bank’s assets. The ratio is supposed to reflect CRA effort compared to a bank’s capacity and would influence a bank’s CRA rating.[9] While the one ratio may have a simplistic allure, it would interfere with the ability of examiners to ensure that banks are meeting their statutory responsibilities. The statute states that banks “have continuing and affirmative obligations to help meet the credit needs of the local communities in which they are chartered.”[10] The key word is local.

One ratio cannot tell an examiner, a bank, or a member of the public how responsive a bank is to its various assessment areas. In contrast, current CRA exams scrutinize the extent to which a bank makes loans, investments, and services to LMI people and communities in its assessment areas. Also, an exam focused on the one ratio would not be able to effectively consider community group comments regarding banks’ records on meeting local needs (Question 11 of the ANPR).

Weighting cannot overcome the flaws of a one ratio. For instance, an investment of $1 million in a distressed community can be weighted by a factor of two, meaning it will count for $2 million in the numerator of the ratio (see Question 10 of the ANPR). Consider how complicated and subjective it would be to do this weighting for banks, particularly those which serve several states. Also, generous and frequent weighting (multiplying loans and investments by 2 or more) could easily result in half or less the dollar amount of loans and investments.

Analysis of Branches and Services Must Remain on CRA Exams

In response to ANPR Question 27, branches must remain on CRA exams because they are critical for helping LMI people obtain loans. Academic research has revealed that home and small business lending increases in LMI neighborhoods with bank branches.[11] In contrast, when branches close, lending decreases for several years, especially small business lending.[12]

The OCC Must not Broaden CRA Away from the Focus on Credit Needs of LMI People and Communities

Industry trade associations have advocated broadening CRA consideration for activities such as infrastructure improvements and financial education for middle- and upper-income people and communities.[13] [14] However, diverting attention away from LMI communities is contrary to Senator Proxmire’s intention that CRA rectify redlining and increase access to credit for underserved populations. Redlining and market imperfections unfortunately continue to afflict LMI communities. Therefore, dilution of attention to LMI communities will significantly decrease lending in them.

The ANPR discusses the possibilities of expanding the range of activities considered by CRA such as digital literacy or internships.[15] However, consideration for activities that do not directly combat redlining and/or lack of access to banking will result in a regulation that frustrates the purpose of CRA to revitalize credit starved communities.

If home and small business lending to LMI people and communities were no longer considered as hinted at in ANPR Question 21, this would violate the intent of Senator Proxmire who was concerned that the agencies were not assessing whether banks were meeting credit needs.[16] In addition, consumer lending meets important needs such as buying vehicles in areas lacking transit. CRA exams must consider consumer lending and ensure that it is responsible and does not violate consumer protection law. Finally, the OCC in Question 23 asks whether Small Business Administration (SBA) standards should be used in evaluating the financing of small businesses. The SBA standards include businesses with several millions of dollars in revenue and would divert CRA exams from their focus on assessing whether banks are meeting the needs of the smallest businesses.[17]

Asset Thresholds for CRA Exams: Reform Must not Reduce Requirements for Any Category of Banks

Eliminating the Intermediate Small Bank (ISB) category as some advocate means that the ISB banks would just have a retail test which does not consider their community development financing. [18] NCRC estimates that ISBs finance about $3 billion annually in CD projects or about the same amount of annual funding as the Community Development Block Grant (CDBG) program. If the CD test is eliminated for ISB banks, their CD financing would plummet.[19] We also oppose any other changes to asset categories that would eliminate the service test and analysis of branching.


Bolstering the effectiveness of CRA would entail increasing opportunities for public input, improving data on CRA exams, mandating the inclusion of affiliates, evaluating bank financing to people and communities of color, and expanding assessment areas. In contrast, the OCC proposes reforms that would result in less lending, investing, and services in LMI communities. These changes include the one ratio, diverting attention from LMI communities, and broadening consideration of activities that are not related to meeting credit and community development needs.

Over the last several months, the OCC has made unilateral changes to CRA that stretch out CRA exams for large banks and weaken fair lending and merger reviews of all banks. The OCC must rescind these changes and align any future changes to the CRA regulation and examination procedures with the Federal Reserve Board and the Federal Deposit Insurance Corporation (FDIC).[20] [21] [22]

We are submitting this letter on behalf of the underserved organizations. If you have any questions, please contact us or Josh Silver, Senior Advisor at NCRC, on 202-628-8866.



John Taylor
President and Founder, NCRC


Jesse Van Tol
Chief Executive Officer, NCRC




National Organizations


Americans for Financial Reform

Center for Responsible Lending

Democracy Collaborative

Leadership Conference on Civil and Human Rights

League of United Latin American Citizens

Local Initiatives Support Corp (LISC)


National Coalition for Asian Pacific American Community Development (CAPACD)

National Alliance of Community Economic Development Association (NACEDA)

National NeighborWorks Association

National Urban League




Alabama Association of Community Development

Building Alabama Reinvestment

Center for Fair Housing, Inc.

Community Action Association of Alabama

Fair Housing Center of Northern Alabama

MLK Avenue Redevelopment Corporation

National Business League of Alabama

Titusville Development Corp

Urban Impact, Inc.



Arizona Housing Coalition

Behold Charities International

Chicanos Por La Causa

Junto Affordable Housing Inc.

Newtown Community Development Corporation

Prima County Community Advocate



Community Resources Technicians

People Trust



Access Plus Capital

American GI Forum

Azul MSI

Black Business Association

California Coalition for Rural Housing

California Community Economic Development Association

California FarmLink

California Housing Partnership

California Reinvestment Coalition

California Resources and Training


CDC Small Business Finance

Center for Urban Economics and Design

Chicana Latina Foundation

City of Livingston

Council of Asian Americans Business Associations CA


Democracy at Work Institute

EAH Housing

El Concilio of San Mateo County

Fathers and Families of San Joaquin

Haven Services

Housing and Economic Rights Advocates

Housing Coalition Educators


Inland Empire Latino Coalition

Law Foundation of Silicon Valley

Montebello Housing Development Corporation

The National Cultural Center of the Native Americans

Neighborhood Housing Services of the Inland Empire

Northern Californian Community Loan Fund


Peoples’ Self-Help Housing

Robert Zdenek Associates- Connecting Communities

Rural Community Assistance Corporation

San Francisco African American Chamber of Commerce

Self-Help Enterprises

Tenderloin Neighborhood Development Corporation (TNDC)

The Central Valley Urban Institute

The Greenlining Institute

UCI Paul Merage School of Business

Vermont Slauson Economic Development Corporation



Douglas County Housing Partnership

First Nations Oweesta Corporation

Mi Casa Resource Center



Concerned Black Clergy Council of Waterbury

Connecticut Citizen Action Group

Hartford Community Loan Fund

Neighborhood Housing Services of Waterbury

Women’s Institute for Housing & Economic Development

Yale University Program for Recovery and Community Health


District of Columbia

Advocates for Elder Justice, Hilda & Charles Mason Charitable Foundation, Inc.

Anacostia Economic Development Corporation

Central American Resource Center (CARECEN)

Housing Up

Latino Economic Development Center

Laura Zam Enterprises


National Association of American Veterans, Inc.

Network for Developing Conscious Communities

Partners for Livable Communities

Romijen Wellness



Be Ready Community Development Corporation


Central Baptist Community Development Corporation

Delaware Community Reinvestment Action Council, Inc.

Edgemoor Revitalization Cooperative, Inc.

Ellendale Community Civic Improvement Association

Habitat for Humanity of New Castle County

Housing Alliance Delaware

National Council on Agricultural Life & Labor Research Fund, Inc. (NCALL)

Nehemiah Gateway Community Development Corp.

Neighborhood House, Inc.

University of Delaware



Affordable Homeownership Foundation Inc.

BBIF Florida

Bright Community Trust

CDC of Tampa


Clearwater Neighborhood Housing Services Incorporated

Community Reinvestment Alliance of South Florida

Consolidated Credit Solutions, Inc.

Debt Management Credit Counseling

FL Alliance of Community Development Corporations

Florida Housing Coalition

Fusilier Realty Group

Future Leaders Community Development Corporation

H.O.M.E.S., Inc.

Haitian American Community Development Corporation

Home Ownership Resource Center of Lee County, Inc.

Housing and Education Alliance

Lee County Housing Development Corp.

Metro North Community Development Corp.

Mezrah Consulting

Miami Beach CDC

Neighborhood Housing Services of South Florida

Neighborhood Renaissance, Inc.

New Urban Development


Real Estate Education And Community Housing Inc.

REVA Development Corporation

Solita’s House Inc.

South Florida CLT

St. Petersburg Neighborhood Housing Services, Inc. (dba Neighborhood Home Solutions)

Struggle for Miami’s Affordable and Sustainable Housing, Inc.

Trinity Empowerment Consortium

Urban Philanthropies

We Help Communities to Develop Corporation

Wealth Watchers Inc.



CCCS of the Savannah Area, Inc.

Community Outreach Training Center, Inc.

D&E, The Power Group

Georgia Advancing Communities Together, Inc.

Housing Justice League

JCVision and Associates, Inc.

National Housing Counseling Agency

Southwest Georgia United Empowerment Zone, Inc.



Council for Native Hawaiian Advancement

Hawai’i Alliance for Community-Based Economic Development

Hawaiian Community Assets



Chicago Community Loan Fund

Chicago Urban League

Economic Growth Corp.

Global Network

Heartland Alliance for Human Needs and Human Rights

Housing Action Illinois


Institute of Cultural Affairs [ICA]-USA

NHS of Chicago

Northwest Side Housing Center

Oak Park Regional Housing Center

Open Communities

Partners in Community Building, Inc.

Spanish Coalition for Housing

Universal Housing Solutions CDC

Woodstock Institute

NHS of Chicago



Community Investment Fund of Indiana

Fay Biccard Glick Neighborhood Center at Crooked Creek

Gary Economic Development Corporation


HOPE of Evansville, Inc.

Irvington Development Organization

John Boner Neighborhood Centers

LaCasa, Inc.

Mapleton Fall Creek Development Corporation

Martin University

Martindale Brightwood Community Development Corporation

Memorial CDC

Northwest Indiana Reinvestment Alliance

NSP Consultants, LLC

Pathfinder Services, Inc.

Prosperity Indiana

Westside Community Development Corporation



River Cities Development Services

Scott County Housing Council



Louisville Affordable Housing Trust


River City Housing

The Urban Coalition of Appraisal Professionals



Foundation for Louisiana

Greater New Orleans Housing Alliance


Kingsley House Inc.

LiftFund Inc.

Multi-Cultural Development Center

Neighborhood Development Foundation

New Day Homeowner Services

People’s Organization of Social Equality

Treme Market Branch

UMOJA Institute of African America Culture Trade and Economic Development Inc.




Common Capital

Dorchester Bay Economic Development Corporation

Fair Housing Center of Greater Boston

Fenway Community Development Corporation

Lawrence CommunityWorks, Inc.

Local Enterprise Assistance Fund (LEAF)

Mass. Association of Community Development Corp.

Massachusetts Affordable Housing Alliance

Massachusetts Communities Action Network

NeighborWorks Southern Mass

Oak Hill CDC

Revitalize Community Development Corporation

Urban Edge



Baltimore Community Lending, Inc.

Baltimore Neighborhoods, Inc.

CityLabs USA

Coppin Heights CDC

Greater Baltimore Community Housing Resource Board

Heritage United Church of Christ


Housing Options & Planning Enterprises, Inc.

Maryland Consumer Rights Coalition

Neighborhood Housing Services of Baltimore

People of Change Coalition

Southeast Community Development Corporation

The Historic Marble Hill Community Association



Coastal Enterprises, Inc.

Genesis Community Loan Fund

Quattrucci & Company



Bridging Communities, INC.

Building Families First Community Organization

Building Movement Project/Detroit People’s Platform


Community Economic Development Association of Michigan

Cooperative Capital

Detroit Homeownership Center CDC

Detroit Non-Profit Housing

Detroit People’s Platform

Fair Housing Center of Metropolitan Detroit

Financial Justice Coalition


Housing Resources, Inc.

Metro Community Development, Inc.

Michigan Community Action

Michigan Community Reinvestment Coalition

Mid Michigan Community Action Agency

Neighborhood Legal Services Michigan

Neighborhood Service Organization (NSO)

New Development Corporation

New Hope Community Development

Southwest Economic Solutions

Southwest Solutions




Asian Economic Development Association

Community Reinvestment Fund, USA

Dayton’s Bluff Neighborhood Housing Services

Jewish Community Action

Mid-Minnesota Legal Aid

Voices for Racial Justice




Community Property Ventures

Consumers Council of Missouri


Forward Through Ferguson

International Institute Community Development Corporation

Justine Petersen

Metropolitan St. Louis Equal Housing and Opportunity Council

NHS of Kansas City, Inc.

Old North St. Louis Restoration Group

R.A.A.- Read, Aim, Advocate


Useful Community Development

Washington University School of Social Work



Breakthrough Community Services, Inc.


Covenant Faith Outreach Ministries Inc./covenantcdc

Golden Triangle Housing Services

Housing Education and Economic Development

Mississippi Housing Partnership



Family Housing Advisory Services

Neighborworks Lincoln


New Mexico

Southwest Neighborhood Housing Services

United South Broadway Corporation


New York

Affordable Housing Partnership Homeownership Center

Albany Community Land Trust

Arbor Housing and Development

Association for Neighborhood and Housing Development (ANHD)

Beaulac Associates LLC

Bridge Street Development Corporation

Buffalo Niagara Community Reinvestment Coalition

Center for NYC Neighborhoods

Central lslip Civic Council

CNY Fair Housing, Inc.

Community Capital New York

Community Development Alliance of the Capital District

Community Loan Fund of the Capital Region, Inc.

Devotion NYC

Empire Justice Center

Fair Finance Watch


Human Development Services of Westchester

La Fuerza Unida, Inc.

Long Island Housing Services, Inc

New Economy Project

New York State Senator James Sanders

New York State Wide Senior Action Council

NHP Foundation

PathStone Enterprise Center

Rockland Housing Action Coalition

Rural housing Opportunities Corp.

St. Nicks Alliance

TSC Grand, Ltd.

United Tenants of Albany, Inc.

White Wing Education Community

University Neighborhood Housing Program


New Hampshire

New Hampshire Community Loan Fund


New Jersey

Fair Housing Council

Jersey Counseling & Housing Development, Inc.

National Housing Institute

New Jersey Association on Correction

New Jersey Citizen Action


Urban League of Essex County



Nevada Legal Services


North Carolina

Action NC

Centre for Homeownership & Economic Development Corporation

Circle of Mercy

Community Link


Durham Regional Financial Center


Henderson & Company

NC Housing Coalition

New Frontier CDC

North Carolina Housing Coalition

Rebuild Durham Inc.

S J Adams Consulting

The Institute of Minority Economic Development

White Oak Foundation Inc.




Advocates for Basic Legal Equality

Akron Baptist Church

Another Chance Ohio

Antioch Baptist Church

Baptist Ministers Conference of Cincinnati

Breaking Chains Inc.

Buckeye Shaker Square Development Corp.

Burten, Bell, Carr Development, Inc.

Catholic Commission of Summit County

Central Ohio Fair Housing Association, Inc.

Charisma Community Connection

Cincinnati Change Inc.

Cincinnati Community Action Agency

City of Bedford Heights

City of Cleveland Heights, Ohio

City of Cleveland- Dept. of Community Development

City of Dayton Human Relations Council

City of South Euclid

CityWide Development Corporation

Cleveland Neighborhood Progress

Collective Empowerment Group

Communities United for Action

Community Action Agency of Cincinnati-Hamilton County

Community Development Corporations Association of Greater Cincinnati

Community Development for All People

Community Housing Solutions

Community Matters

County Corp

Detroit Shoreway Community Development Org.


Economic and Community Development Institute

Education Motivation Success, Inc.

Empowering and Strengthening Ohio’s People (ESOP)

Fair Housing Center

Fair Housing Contact Service

Fair Housing Resource Center, Inc.

Faith Community Alliance of Greater Cincinnati

Famicos Foundation

Federation of Network Ministries

Friends of the African Union Chamber of Commerce

Greater Cincinnati Microenterprise Initiative (GCMI)

Greater Cleveland Reinvestment Coalition

Greater Dayton Minority Business Assistance Center

Habitat for Humanity of Greater Dayton

Hamilton County Community Reinvestment Group

Harrison Township

Heart to Heart Family Support Center

Helping Hands Community Outreach

Home Repair Resource Center

Homes on the Hill, CDC

Isonomy Consulting

Jerry Sykes, Toledo City Councilman



L.A. Keyz Financial Services

Madisonville Community Urban Redevelopment Corporation

Metro West Community Development Organization

Miami Valley Fair Housing Center, Inc.

Miami Valley Urban League

Mustard Deed Development Center

Nazareth Housing Dev. Corp.

Neighborhood Housing Services of Greater Cleveland

NeigborWorks Collaborative of Ohio

Ohio CDC Association

Ohio Fair Lending

Omega Community Corporation

One South Euclid

Peter Ujvagi, Toledo City Council Member

Rebuilding Together Dayton

Slavic Village Development

Small Business Development Center at TEC

The Fair Housing Center

The Pride Through Empowerment Foundation, Inc.

Village Capital Corporation

Working in Neighborhoods

YWCA Dayton



Mvskoke Loan Fund



CASA of Oregon

Community Housing Fund

Community Development Corporation of Oregon

Grounded Solutions Network

Kate Allen Community Development Services

Neighborhood Economic Development Corporation


Redix Consulting Group, LLC

REACH Community Development

Willamette Neighborhood Housing Services



Allentown Housing Authority


Center for Family Services, Inc.


Community Action Committee of the Lehigh Valley, Inc.

Community First Fund

Community Neighbors United

Five/Four Advisors

Hilltop Alliance

Lancaster Equity CDC

Neighborhood Housing Services of Greater Berks, Inc.

Oakland Planning and Development Corporation

Philadelphia Association of Community Development

Philadelphia Chinatown Development Corporation

Pittsburgh Community Reinvestment Group

Southwest Community Development Corporation

United Communities Southeast Philadelphia

Uptown Partners of Pittsburgh



Rhode Island

Capital Good Fund

Church Community Housing Corporation

Housing Network of Rhode Island

HousingWorks RI

NeighborWorks Blackstone River Valley


South Dakota

GROW South Dakota


South Carolina

Greenville County Redevelopment Authority



BLDG Memphis

Chattanooga Organized for Action

Good Neighbor Foundation HomeOwnership Center

Latino Memphis

Lincoln Park Neighborhood Association

Memphis Urban League

New Level Community Development Corp

Tennessee Fair Housing Council

The Fifteenth Avenue Baptist CDC

You Can Make It HomeOwnership Center



Arx Advantage Housing Consultants

BCL of Texas

Community Council of Greater Dallas

Covenant Community Capital


Dallas City Homes

El Paso Collaborative for Community & Economic Development

Frameworks Community Development Corporation

Harlingen CDC

Home Sweet Home Community Redevelopment

Housing Channel

Humanitas Community Development Corporation

Jefferson Community Housing Development Foundation, Inc.

Mathis Economic Development Corporation

New Hope Housing, Inc.

Our Casas Resident Council INC.


Pine Place Development, LLC


Southeast Houston CDC

Texas Homeless Network

The Alliance


VN TeamWork, Inc.

Women Opting for More Affordable Housing Now, Inc. (WOMAN, Inc.)



Jon M. Huntsman School of Business at Utah State University

Neighborhood Nonprofit Housing Corporation



Fair Housing Project, CVOEO

Housing Vermont



Community Business Partnership

Emerging Financial Concepts

Housing Opportunities Made Equal of Virginia


Southside Community Development and Housing Corporation



Beacon Development Group

Greenfield Institute

Northwest Fair Housing Alliance



Citizen Action of Wisconsin

Forward Community Investments

Havenwoods Economic Development Corp

Inner City Redevelopment Corp.

Metropolitan Milwaukee Fair Housing Council

NeighborWorks Green Bay

Nothing Less, Inc.

Riverworks Development Corporation

Urban Economic Development Association of Wisconsin, Inc.

Wisconsin Partnership for Housing Development



[1] NCRC Forecast: Weakening the Community Reinvestment Act Would Reduce Lending by Hundreds of Billions of Dollars, September 2018,

[2] See Bank of the Internet’s CRA exam,

[3] Office of the Comptroller of the Currency, Reforming the Community Reinvestment Act Regulatory Framework Advance Notice of Proposed Rulemaking (ANPR), Federal Register, Vol. 83, No. 172, Wednesday, September 5, 2018, Proposed Rules p. 45057,

[4] Lei Ding and Leonard Nakamura, Don’t Know What You Got Till It’s Gone: The Effect of the Community Reinvestment Act on Mortgage Lending in the Philadelphia Market, Federal Reserve Bank of Philadelphia, Working Paper 17-15, June 2017,

[5] Congressional Record, June 6, 1977, p. 17630.

[6] Examples of people of color analyzed by CRA exams include; Federal Reserve Bank of Richmond, CRA Exam of Signet Bank, January 1996, pgs. 18-20, and Office of Thrift Supervision CRA Exam of CenFed Bank, November 1995, p. 9,

[7] CRA exams today have a point score range of 1 to 24 that is not intuitive, and the points are not publicly released.

[8] OCC, Description: Supervisory Policy and Processes for Community Reinvestment Act Performance Evaluations, OCC Bulletin 2018-17, June 2018,

[9] Office of the Comptroller of the Currency (OCC), Advance Notice of Proposed Rulemaking (ANPR), Federal Register, Vol. 83, No. 172, Wednesday, September 5, 2018,, pgs. 45056 and 45057.

[10] Section 802(a)(3) of the CRA statute.

[11] For a literature review of the impact of branches and assessment areas, see Josh Silver, The Importance of CRA Assessment Areas and Bank Branches, NCRC, June 2018,

[12] Hoai-Luu Q. Nguyen, Do Bank Branches Still Matter? The Effect of Closings on Local Economic Outcomes, December 2014,

[13] Rachel Witkowski, Will CRA Finally Get its Makeover, American Banker, March 9

[14] American Bankers Association, CRA Modernization, Meeting Community Needs and Increasing Transparency, December 2017, p. 2,

[15] ANPR, page 45057-45058.

[16] Congressional Record – Senate, January 24, 1977, p. 1958.

[17] U. S. Small Business Administration Table of Small Business Size Standards Matched to North American Industry Classification System Codes. Version 2017. Available online at

[18] American Bankers Association, Second Published Request for Comments Under the Economic Growth and Regulatory Paperwork Reduction Act of 1996 (February 13, 2015), p. 7,

[19] NCRC, Intermediate Small Banks, the Forgotten but Significant Resource for Affordable Housing and Community Development,

[20] OCC Bulletin 2018-17, June 15, 2018,

[21] OCC Bulletin 2018-23, August 15, 2018,

[22] OCC, Impact of CRA Ratings on Licensing Applications, November 2017,

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Redlining and Neighborhood Health

Before the pandemic devastated minority communities, banks and government officials starved them of capital.

Lower-income and minority neighborhoods that were intentionally cut off from lending and investment decades ago today suffer not only from reduced wealth and greater poverty, but from lower life expectancy and higher prevalence of chronic diseases that are risk factors for poor outcomes from COVID-19, a new study shows.

The new study, from the National Community Reinvestment Coalition (NCRC) with researchers from the University of Wisconsin–Milwaukee Joseph J. Zilber School of Public Health and the University of Richmond’s Digital Scholarship Lab, compared 1930’s maps of government-sanctioned lending discrimination zones with current census and public health data.

Table of Content

  • Executive Summary
  • Introduction
  • Redlining, the HOLC Maps and Segregation
  • Segregation, Public Health and COVID-19
  • Methods
  • Results
  • Discussion
  • Conclusion and Policy Recommendations
  • Citations
  • Appendix

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